Making Scotland's buildings safer for people: consultation

Part 2 - Fire Safety in Building Standards

Overview

The report of the Fire Safety Review Panel can be accessed at Annex B. You may wish to read the report before adding your response to the questions set out in this document.

The panel identified five themes covering their recommendations.

• Structure of building standards and supporting guidance
• Fire safety engineering
• External walls and cladding
• Escape
• Automatic fire suppression systems.

Structure of building standards and supporting guidance

Compliance with building standards is mandatory and following the guidance in the Technical Handbooks is intended to assist in achieving compliance. This current structure of mandatory functional standards supported with performance based or prescriptive guidance in the Technical Handbooks works well and the review panel’s view was that it should be retained. However, to make clearer their existing status, functions and limitations there is a need to reinforce the principle that while compliance with the building standards is the mandatory requirement, this is possible without following the guidance in the Technical Handbooks. Alternative compliance pathways with equal status could be used.

When alternative pathways to compliance are used it is important to ensure that those designing and those verifying the designs must be competent to do so.

Proposals - Structure of building standards and supporting guidance

The following proposals are intended to provide a framework for making the status, functions and limitations of the guidance in the Technical Handbooks clearer. In addition, the panel agreed the need for minor changes to the wording of some of the buildings standards. These are not to change policy intent but simply to remove ambiguities and close potential loopholes. This will require the Building (Scotland) Regulations 2004 to be amended and will be subject to legislative timetable.

1. The introduction of alternative guidance to make clear that there is more than one way of achieving compliance with the functional technical standards. A model proposed is:

• A prescriptive set of guidance, for use by all;
• A middle set of guidance, combining engineering principles and prescribed or performance requirements, for those competent to use it; and
• Design from a fully performance based fire safety engineering approach, from first principles, only by those competent to do.

2. The annexes in the Technical Handbooks for residential care buildings, hospitals and enclosed shopping centres should not be used without sufficient understanding and experience. They should be published separately so they can be individually reviewed and updated as required.

3. An additional Technical Handbook for simple domestic detached and semi-detached dwellings (up to 3 storeys) should be introduced as a means of compliance with fire, and all applicable building standards and sections of the Handbooks.

Question 2.1: Do you agree that the guidance should be developed to make clear that there is more than one way of achieving compliance with the mandatory functional standards?

Question 2.2: Do you agree that the annexes in the Technical Handbooks for residential care buildings, hospitals and enclosed shopping centres should be published separately?

Question 2.3: Do you agree that an additional Technical Handbook for simple domestic detached and semi-detached dwellings (up to 3 storeys) should be introduced as a means of compliance with fire, and all applicable building standards and sections of the Handbooks?

Verification of fire safety engineering

The introduction of a new framework for making the status, functions and limitations of the guidance in the Technical Handbooks clearer must also be accompanied by additional guidance for verifiers on how to verify compliance with these different guidance sets. The proposed model is set out in the previous section and proposals.

The review panel agreed the need to develop a better mechanism for the verification of fire safety engineering solutions for buildings with more complex design strategies. They also recognised that there are a limited number of fully performance based “fire safety engineering” approach designs, probably less than 20 each year and that the skills and experience needed to verify these may be limited and not freely available across all verifying authorities.

In considering this issue the panel reflected on whether or not a system for Building Standard Certification of Design for Section 2: Fire could be developed and also on the recent research commissioned by the Scottish Government, relating to the creation of a central verification hub. The research, Feasibility of a Centralised Hub for the Verification of Complex Fire Engineered Solutions in Scotland, by Meacham Associates can be accessed at Annex B.

Proposals - Fire safety engineering

The following proposal is intended to provide a framework for a better mechanism for the verification of fire safety engineering solutions for complex buildings.

4. That a central hub be developed with responsibility for verifying fully performance based fire safety engineering approaches, developed from first principles.

5. That consideration be given to a longer term aim of a certification scheme for fire engineering.

Question 2.4: Do you agree that a national “hub” approach should be developed to share expertise and skills and be responsible for verifying fully performance based “fire safety engineering designs”?

Question 2.5: Do you agree that consideration should be given to a certification scheme for fire engineering?

Reaction to Fire - External walls and cladding

This section relates to the specific details of the functional standards and the current guidance in the Technical Handbooks. In 2018 the Scottish Government commissioned research on ‘Regulatory Appropriateness of Currently Cited Reaction to Fire Tests in Technical Handbook - Section 2: Fire - Standards 2.4 - 2.7’ (this can be accessed at Annex B ). The research concluded that the currently cited British Standard and harmonised European reaction to fire tests should not be used for external cladding systems as they are designed for internal wall and ceiling linings. Furthermore the research highlighted that the European Harmonised tests offer a better and more cohesive structure for testing “reaction to fire”.

It was also the view of the review panel who concluded that the current guidance which cited both British Standard ( BS) ‘reaction to fire’ tests was no longer required as they are no longer being reviewed by the British Standards Institution. Going forward only the European harmonised tests should be applied to Euro class A1 and A2 cladding materials and internal wall and ceiling linings. The linked group of standards that are all related to the reaction of materials to fire comprise:

• Cavities (2.4)
• Internal linings (2.5)
• Spread to neighbouring buildings (2.6)
• Spread on external walls (2.7)

Although Scottish building standards already require robust fire tests for high rise domestic buildings there is the need to consult on the impact of proposals on high rise non-domestic buildings and low rise higher risk assembly, entertainment, residential care buildings and hospitals.

Proposals - External walls and cladding

The following proposals are intended to update the simple guidance to building standards relating to external cladding, cavities, internal lining and fire spread on external walls (standards 2.4 to 2.7):

6. That the reference to British Standard reaction to fire tests be removed from the Technical Handbook. It is also recommend that a suitable transition period is agreed and signalled to industry.

7. The trigger height for non-combustibility of external wall cladding should be reduced from 18m to 11m. This is the height the fire service is expected to reach from a ground level mounted water jet. Alternatively, the cladding system would need to pass a full scale fire test to BS 8414 (and BR135). The review panel concluded that the BS 8414 test was robust when compared with other full scale tests around the world but understood that the standard is likely to be reviewed following the Grenfell Tower fire.

8. Currently, thermal insulation material exposed in a cavity of an external wall requires to be non-combustible where the building has a storey at a height of more than 18m above the ground or meets the full scale fire tests to BS 8414 (and BR 135). This should also be reduced to a trigger height of 11m.

9. It is recommended that the revised guidance will equally apply to domestic and non-domestic buildings.

10. That the guidance in the Technical Handbooks should only be changed as described in respect of the reaction to fire tests referred to above, i.e. the proposed removal of reference to the BS 476 series of fire tests.

Question 2.6 Do you agree that the reference to British Standards Reaction to Fire Tests BS 476 should be removed from the Technical Handbook?

Question 2.7: Do you agree that only A1 and A2 materials, using the European Harmonised “reaction to fire tests”, should be required for external walls or insulation exposed in a cavity of a high rise building (domestic and non-domestic) with a storey at a height of more than 11m above ground?

Question 2.8: Do you agree that only A1 and A2 materials, using the European Harmonised “reaction to fire tests”, should be required for external walls or insulation exposed in a cavity of entertainment and assembly buildings, residential care homes and hospitals of any height?

Question 2.9: Do you agree that BS 8414 (and BR135) may still be used as an alternative method of providing evidence to show compliance?

Escape

The basis for guidance in the Technical Handbooks regarding escape in domestic high rise buildings is the ‘stay put/defend in place’ strategy. This strategy is based on the fire safety design of buildings, for example each flat is a self-contained fire “compartment” and was endorsed by the review panel as the basis for continued guidance. It was also acknowledged that, whilst uncommon, there may be occasions where total evacuation is deemed necessary.

In light of the Grenfell Tower tragedy the review panel sought to establish if there were any additional requirements for escape that could ensure future domestic buildings above 18m were even safer. The means of escape and alarm and evacuation sounders inside flats were the focus of considerations. No clear consensus was reached on the issue of two staircases, however the view of the chair, which was endorsed by all members of the international sub-group, was that there was a need to require at least two stairways in high rise domestic buildings with a storey at a height of 18m. This is firstly to provide an alternative in case of the failure of the first stairway and secondly to provide a route for escape if the other stairway is being used for fire-fighting operations.

Proposals - Escape

11. To provide for the rare situations where entire building evacuation is necessary it is proposed that fire service activated evacuation sounders be required in each flat for new domestic buildings over 18m.

12. That for new domestic buildings over 18m two stairways should be required.

Question 2.10: Do you agree fire service activated evacuation sounders should be required in each flat in new domestic buildings which have a storey at a height of more than 18m above ground level?

Question 2.11 Do you agree that two stairways should be required for new domestic buildings which have a storey at a height of more than 18m above ground level?

Automatic fire suppression systems

The need for certain building types to have automatic fire suppression systems fitted has been the subject of much debate in recent years. The Welsh Assembly, under the Domestic Fire Safety (Measure) 2011, introduced the requirement for automatic fire suppression systems to be fitted in all new build homes in 2016 and other residential buildings in 2014.

The Ministerial Working Group on Building and Fire Safety tasked the review panel to consider if any changes or additions were necessary to the mandatory requirements for buildings requiring automatic fire suppression systems.

In considering this the panel agreed a series of principles which should underlie any decision to expand the mandatory requirement. These are that decisions should:

• be evidence based, using fire statistics and recognising continuing demographic and social changes;
• consider the cost-effectiveness of such requirements;
• recognise the public desire for action after Grenfell; and
• learn from the Welsh experience of introducing automatic fire suppression systems in domestic buildings.

The panel also agreed that it was not acceptable to “trade-off” the provision of sprinklers as compensation for a reduction in the number of stairs or a lower fire safety performance of the external cladding.

The issue of vulnerability and targeting automatic suppression to those groups that would receive most benefit was a key consideration for the panel. There were differences of opinion among Panel members on the necessity of increasing the number of building types required to install automatic fire suppression systems.

However, the panel members agreed that the following building types should be required to have automatic fire suppression systems:

• Houses in Multiple Occupation ( HMOs) used for “care” 24/7, which will necessitate a very careful definition of “care” linked to Care Inspectorate definitions;
• large HMOs (10 or more residents);
• all flats.

In May 2018 David Stewart MSP lodged a private members bill seeking to introduce automatic fire suppression systems in all new build social housing in Scotland.

In June 2018, the Scottish Government committed to initiate legislation to require all new build Scottish social housing to be fitted with automatic fire suppression systems.

Proposals - Automatic fire suppression systems

13. The list of new buildings (included conversions) with a mandatory requirement for automatic fire suppression systems should be expanded to include:

• Houses in Multiple Occupation ( HMOs) used for “care” 24/7, which will necessitate a careful definition of “care” linked to Care Inspectorate definitions;
• large HMOs (10 or more residents);
• all flats.

Question 2.12: Do you agree that new HMOs used for “care” 24/7 should be included in the list of buildings with a mandatory requirement for automatic fire suppression systems?

Question 2.13: Do you agree that new HMOs with 10 or more occupants should be included in the list of buildings with a mandatory requirement for automatic fire suppression systems?

Question 2.14: Do you agree that new flats should be included in the list of buildings with a mandatory requirement for automatic fire suppression systems?